What is CIT v. Reliance Utilities & Power Ltd. authority for?

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

How many judgments cite CIT v. Reliance Utilities & Power Ltd.?

2,118 judgments on BharatTax cite CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), spanning 2013 to 2026.

Which sections of the Income Tax Act does CIT v. Reliance Utilities & Power Ltd. come up under?

It is most often cited in judgments turning on Section 14A, Section 36(1)(iii), Section 143(3), Section 115JB, Section 8D, Section 10(34).

CIT v. Reliance Utilities & Power Ltd. (313 ITR 340)

Indraprastha Gas Limited, Delhi vs. JCIT OSD Range-10, Delhi

In the result, the appeal of the assessee is allowed as above

ITA 2422/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 14ASection 32(1)(iia)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.2422/Del/2025, A.Y. 2018-19 Indraprastha Gas Limited Joint Commissioner of Plot No. 4, IGL Bhawan, Income Tax (OSD), Range-10, Sector-4, R. K. Puram, Vs. C. R. Building, I. P. Estate, New Delhi- 110022 New Delhi PAN: AAACI5076R (Appellant) (Respondent) Appellant by Sh. Rajat Jain, CA Sh. Ashish Mendiratta, CA Respondent by Sh. Jitender Singh, CIT DR Date of Hearing 30/09/2025 Date of Pronouncement 30/10/2025 ORDER PER AVDHESH KUMAR MISHRA,…

Moorgate Industries India Pvt Ltd, Mumbai vs. DCIT Central Circle 3(3), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 4282/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Oct 2025AY 2011-12

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 14ASection 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SHRI ARUN KHODPIA (ACCOUNTANT MEMBER) I.T.A. No. 4282/Mum/2025 Assessment Year: 2011-12 Moorgate Industries Vs. DCIT Central Circle- India Pvt Ltd 3(3) 1505, 15th Floor, Plot No B Central Circle 3(3), 3, Maurya Garden, N R Kautilya Bhavan Shalimar Maurya bldg, N Bandra-Kurla R Shalimar Maurya Bldg, Complex, Mumbai- Linking Road, Andheri, 400051 Mumbai-400102 PAN: AAHCS9299R (Appellant) (Respondent) Appellant by Shri Gunjan Kakkad Respondent by Shri Annavaran Kosuri, SR. A.R. Date of Hearing 04.09.2025 Date…

Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai vs. Welspun Living Limited, Mumbai

In the result, the appeal by the Revenue for the assessment year 2015-

ITA 3697/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Oct 2025AY 2015-16

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri Harsh KapadiaFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 115Section 14ASection 250

…y infirmity in the findings of the learned CIT(A) in deleting the disallowance made under Rule 8D(2)(ii) of the Rules by placing reliance upon the decision of the Hon’ble Jurisdictional High Court in CIT vs. Reliance Utilities & Power Ltd., reported in [2009] 313 ITR 340 (Bom.) and CIT vs. HDFC Bank Ltd., reported in [2014] 366 ITR 505 (Bom.). 16. Insofar as the direction of the learned CIT(A) as regards the disallowance made under Rule 8D(2)(iii) of the Rules, we find that the Special Bench of the Tribunal in Vireet Investment (P.) Ltd. (supra), held that only those investments are to be considered for computin…

Deputy Commissioner of Income Tax, Central Circle 3(3), Mumbai vs. Welspun Living Limited, Mumbai

In the result, the appeal by the Revenue for the assessment year 2015-

ITA 3696/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri Harsh KapadiaFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 115Section 14ASection 250

…y infirmity in the findings of the learned CIT(A) in deleting the disallowance made under Rule 8D(2)(ii) of the Rules by placing reliance upon the decision of the Hon’ble Jurisdictional High Court in CIT vs. Reliance Utilities & Power Ltd., reported in [2009] 313 ITR 340 (Bom.) and CIT vs. HDFC Bank Ltd., reported in [2014] 366 ITR 505 (Bom.). 16. Insofar as the direction of the learned CIT(A) as regards the disallowance made under Rule 8D(2)(iii) of the Rules, we find that the Special Bench of the Tribunal in Vireet Investment (P.) Ltd. (supra), held that only those investments are to be considered for computin…

DCIT Central Circle-06, New Delhi vs. Praveen Kumar Jolly, New Delhi

In the result, appeal of the Revenue in No

ITA 1654/DEL/2023[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2011-12] Dcit, Vs Praveen Kumar Jolly, Central Circle-06, 39/1, East Patel Nagar, New Delhi New Delhi-110008. Pan-Aagpj0144C Appellant Respondent

Section 139(1)Section 147Section 148Section 250Section 68

…ITA No.1654/Del/2023 & C.O-134/Del/2023 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “A” BENCH: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2011-12] DCIT, vs Praveen Kumar Jolly, Central Circle-06, 39/1, East Patel Nagar, New Delhi New Delhi-110008. PAN-AAGPJ0144C APPELLANT RESPONDENT C.O.No.-134/Del/2023 [In ITA No.1654/Del/2023] [Assessment Year : 2011-12] Praveen Kumar Jolly, vs DCIT, 39/1, East Patel Nagar, Central Circle-06, New Delhi-110008. New Delhi PAN-AAGPJ0144C APPELLANT RESPONDENT Revenue by Shri Ajay Kumar Arora, Sr.DR Assessee b…

DCIT, New Delhi vs. M/S. Vodafone Essar Digilink Ltd., New Delhi

ITA 1158/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Ketan Ved & Shri Ninad PatadeFor Respondent: Shri Pankaj Kumar

Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

…ee surplus funds and such funds are utilised as interest free advances even for a non-business purpose, there cannot be any disallowance of interest paid on interest bearing loans. The Hon'ble Bombay High Court in CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340/178 Taxman 135, has held that where an assessee possessed sufficient interest free funds of its own which were generated in the course of relevant financial year, apart from substantial shareholders' funds, presumption stands established that the investments in sister concerns were made by the assessee out of interest free funds and, therefore, n…

Vodafone Digilink Limited, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

ITA 1073/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

…ee surplus funds and such funds are utilised as interest free advances even for a non-business purpose, there cannot be any disallowance of interest paid on interest bearing loans. The Hon'ble Bombay High Court in CIT v. Reliance Utilities & Power Ltd. [2009] 313 ITR 340/178 Taxman 135, has held that where an assessee possessed sufficient interest free funds of its own which were generated in the course of relevant financial year, apart from substantial shareholders' funds, presumption stands established that the investments in sister concerns were made by the assessee out of interest free funds and, therefore, n…

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…bers of India Ltd. v. CIT: 134 ITR 219 (Cal.) - approved by Supreme Court in the case of East India Pharmaceutical Works Ltd. v. CIT: 224 ITR 627  Alkali & Chemical Corp. of India v. CIT: (1986) 161 ITR 820 (Cal.)  CIT v. Reliance Utilities and Power Ltd.: 313 ITR 340 (Bom.)  CIT vs. M/s. Ashok Commercial Enterprises: ITA No. No.2985 of 2009 (Bom)  Gujarat State Fertilizers and Chemicals Ltd.: 358 ITR 323 (Guj)  Hero Honda Finlease Ltd vs. ACIT: ITA No. 3726 & 6102/Del/2012 (Del) 8. Further he submitted that interest expenditure cannot be disallowed under section 14A where the assessee had surplus funds and…

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…bers of India Ltd. v. CIT: 134 ITR 219 (Cal.) - approved by Supreme Court in the case of East India Pharmaceutical Works Ltd. v. CIT: 224 ITR 627  Alkali & Chemical Corp. of India v. CIT: (1986) 161 ITR 820 (Cal.)  CIT v. Reliance Utilities and Power Ltd.: 313 ITR 340 (Bom.)  CIT vs. M/s. Ashok Commercial Enterprises: ITA No. No.2985 of 2009 (Bom)  Gujarat State Fertilizers and Chemicals Ltd.: 358 ITR 323 (Guj)  Hero Honda Finlease Ltd vs. ACIT: ITA No. 3726 & 6102/Del/2012 (Del) 8. Further he submitted that interest expenditure cannot be disallowed under section 14A where the assessee had surplus funds and…

JCIT(OSD) Central Circle 1, Jhandewalan vs. Sahara India Real Estate Corporation Ltd., Lucknow

ITA 1085/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Oct 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Ajay Vohra, Sr. Adv. &For Respondent: Sh. Mahesh Kumar, CIT-DR

Section 143(3)

…olvendum in future it cannot be said that any income has accrued to him. The mere expression "earned" In the sense of rendering the services etc. by itself is of no avail......." 19. The Bombay High Court in the case of CIT Vs. Reliance Utilities & Power Ltd. 313 ITR 340 (Bom.) has held that if there are funds available both Interest-free and overdraft and/or loans taken, then a presumption would arise that Investments would be out of the interest- free fund generated or available with the company, if the interest-free funds were sufficient to meet the Investments. The relevant portion of the judgement of Bombay…